0 UNITED STATES NUCLEAR REGULATORY COMMISSION Z0 WASHINGTON, D. C. 20555 August 23, 1990 Docket Nos. 50-269, 50-270, 50-287 50-369, 50-370, 50-413, 50-414 LICENSEE: Duke Power Company FACILITIES: Oconee Nuclear Station, Units 1, 2 and 3 McGuire Nuclear Station, Units 1 and 2 Catawba Nuclear Station, Units I and 2 SUbJECT: SUMMARY OF JULY 16, 1990 INTERFACE MEETING WITH DUKE POWER COMPANY On July 16, 1990, the NRC staff met at the general office of the Duke Power Company (Duke) in Charlotte, NC to discuss licensing and regulatory issues. This meeting was part of a continuing series of meetings held three times annually. Representatives of the Duke corporate office, the three Duke nuclear stations, NRC Resident Inspection staff and NRR participated in the meeting. An agenda of the meeting is included as Enclosure 1. After opening remarks, Duke made a presentation on initiatives undertaken in the Duke Quality Assurance (QA) Programs. The presentation covered QA per formance assessment, training initiatives, Self Initiated Technical Audit program process and status, and enhancements to the QA verification process. The next presentation discussed the Transmission Department (TD) organization relationship to station management and TD training, procedures and work control system. Following those presentations, a representative from the NRC Office of Enforcement made a presentation on the enforcement policy in the area of maintenance violations. He indicated that escalated enforcement could be taken for severity level I, II, or III violations that were caused by maintenance program deficiencies which could have been prevented by proper implementation of the Commission's Revised Policy Statement on the Maintenance of Nuclear Power Plants. Such enforcement actions would be submitted to the Commission for review. The process by which the region recommends severity levels and civil penalties remains unchanged. During the presentation, Duke requested that the NRC allow licensees an opportunity to make an additional presentation after the initial enforcement conference, if changes to the original severity level or civil penalty are made. The Catawba Station Manager then presented an analysis of the unavailability rate for the Catawba Auxiliary Feedwater system. Following a presentation on the status of the Duke Design Basis Documentation program, the NRC made a pre sentation on the background and status of revisions to the approved source term. 9009040C)48 90823 PDR ADOCK 05000269 - -- ___ PDC
FACILITIES: Oconee Nuclear Station, Units 1, 2 and 3 McGuire Nuclear Station, Units 1 and 2 Catawba Nuclear Station, Units I and 2
SUbJECT: SUMMARY OF JULY 16, 1990 INTERFACE MEETING WITH DUKE POWER COMPANY
On July 16, 1990, the NRC staff met at the general office of the Duke Power Company (Duke) in Charlotte, NC to discuss licensing and regulatory issues. This meeting was part of a continuing series of meetings held three times annually. Representatives of the Duke corporate office, the three Duke nuclear stations, NRC Resident Inspection staff and NRR participated in the meeting. An agenda of the meeting is included as Enclosure 1.
After opening remarks, Duke made a presentation on initiatives undertaken in the Duke Quality Assurance (QA) Programs. The presentation covered QA performance assessment, training initiatives, Self Initiated Technical Audit program process and status, and enhancements to the QA verification process. The next presentation discussed the Transmission Department (TD) organization relationship to station management and TD training, procedures and work control system.
Following those presentations, a representative from the NRC Office of Enforcement made a presentation on the enforcement policy in the area of maintenance violations. He indicated that escalated enforcement could be taken for severity level I, II, or III violations that were caused by maintenance program deficiencies which could have been prevented by proper implementation of the Commission's Revised Policy Statement on the Maintenance of Nuclear Power Plants. Such enforcement actions would be submitted to the Commission for review. The process by which the region recommends severity levels and civil penalties remains unchanged. During the presentation, Duke requested that the NRC allow licensees an opportunity to make an additional presentation after the initial enforcement conference, if changes to the original severity level or civil penalty are made.
The Catawba Station Manager then presented an analysis of the unavailability rate for the Catawba Auxiliary Feedwater system. Following a presentation on the status of the Duke Design Basis Documentation program, the NRC made a presentation on the background and status of revisions to the approved source term.
9009040C)48 90823 PDR ADOCK 05000269 - -- ___ PDC
- 2 - August 23, 1990
Future revisions are not expected to significantly affect currently licensed plants and are not expected to result in changes in the size of Emergency Planning Zones.
At the conclusion of the meeting, a tour was taken of the Duke System Dispatchers center and the Catawba/McGuire Crisis Management Center. The participants then briefly met in three groups to discuss plant-specific issues relating to Oconee, McGuire and Catawba.
Meeting participants are listed in Enclosure 2. Handouts used during the presentation are provided in Enclosure 3.
Leonard A. Wiens, Project Manager Project Directorate 11-3 Division of Reactor Projects I/II
Enclosures: As stated
cc/w enclosures: See next page
Db Docket File OGC NRC PDR E. Jordan Local PDR NRC Participants (See Enclosure 2) F. Maraglia ACRS (10) J. Partlow R. Borchardt PDII-3 R/F D. Matthews L. Wiens
OFC . :PDII-3 PM:PDII-3 D:P& NAME EIngram LWiens DMat hews DATE 1 / 90 f/9i/90 /go/0
OFFICIAL RECORD COPY Document Name: DUKE INTERFACE MEETING SUMMARY
Duke Power Company Catawba Nuclear Station McGuire Nuclear Station Oconee Nuclear Station
cc: A.V. Carr, Esq. North Carolina Electric Membership Duke Power Company 3400 Sumner Boulevard 422 South Church Street P.O. Box 27306 Charlotte, North Carolina Raleigh, North Caroline 27611
J. Michael McGarry, III, Esq. Saluda River Electric Cooperative, Bishop, Cook, Purcell and Reynolds Inc. 1400 L Street, N.W. P.O. Box 929 Washington, D.C. 20005 Laurens, South Carolina 29360
North Carolina MPA-1 Senior Resident Inspector Suite 600 Route 2, Box 179N 3100 Smoketree Ct. York, South Carolina 29745 P.O. Box 29513 Raleigh, North Carolina 27626-0513 Regional Administrator, Region II
U.S. Nuclear Regulatory Commission Ms. S. S. Kilborn 101 Marietta Street, N.W., Suite 2900 Area Manager, Mid-South Area Atlanta, Georgia 30323
ESSD Projects Westinghouse Electric Corp. Mr. Heyward G. Shealy, Chief MNC West Tower - Bay 239 Bureau of Radiological health P.O. Box 355 South Carolina Department of Health Pittsburgh, Pennsylvaria 15230 and Environmental Control
2600 Bull Street County Manager of York County Columbia, South Carolina 29201 York County Courthouse York, South Carolina 29745 Ms. Karen E. Long
Assistant Attorney General Richard P. Wilson N.C. Department of Justice Assistant Attorney General P.O. Box 692 S.C. Attorney General's Office Raleigh, North Carolina 27602 P.O. Box 11549 Columbia, South Carolina 29211 Mr. Robert G. Morgan
Nuclear Production Department Piedmont Municipal Power Agency Duke Power Company 121 Village Drive P.O. Box 33189 Greer, South Caroline 29651 Charlotte, North Carolina 28241
Mr. Alan R. Herdt, Chief Dr. John M. Barry Project Branch #3 Department of Environmental Health U.S. Nuclear Regulatory Commission Pecklenburg County 101 Marietta Street, N.W., Suite 2900 1200 Blythe Boulevard Atlanta, Georgia 30323 Charlotte, North Carolina 28203
Duke Power Company -2
cc: County Manager of Mecklenburg County Honorable James M. Phinney 720 East Fourth Street County Supervisor of Oconee County Charlotte, North Carolina 28202 Walhalla, South Carolina 29621
Mr. J. S. Warren Mr.- Paul Guill Duke Power Company Duke Power Company Nuclear Production Department P.O. box 33189 P.O. Box 33189 422 South Church Street Charlotte, North Carolina 28242 Charlotte, North Carolina 29621
Senior Resident Inspector Mr. H. B. Tucker, Vice President c/o U.S. Nuclear Regulatory Commission Nuclear Production Department 12700 Hagers Ferry Road Duke Power Company Huntersville, North Carolina 28078 P.O. Box 1007
Charlotte, North Carolina 28201-1007 Senior Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 610 Seneca, South Carolina 27611-7687
Mr. Dayne H. Brown, Director Department of Environmental,
Health and Natural Resources Division of Radiation Protection P.O. Box 27687 Raleigh, North Carolina 27611-7687
Mr. Robert B. Borsum Babcock & Wilcox Nuclear Power Division Suite 525 1700 Rockville Pike Rockville, Maryland 20852
Office of Intergovernmental Relations 116 West Jones Street Raleigh, North Carolina 27603
Enclosure 1
Duke/NRC Interface Meeting July 16, 1990
Wachovia Center/WC-2669 Charlotte, N.C.
8:30 Coffee
9:00 Introductions/Opening Remarks Mike Tuckman
9:15 Quality Assurance John Frye Program Initiatives Doug Franks
10:15 Break
10:30 Transmission Department Roy Holmes Interface Jeff Ashe
11:30 Design Basis Documentation Jack Peele Program Status
12:00 Catawba Emergency Feedwater Pump Tony Owen
12:15 Lunch
1:15 NRC Presentation Dave Matthews
2:15 Corporate Office Tour Mike Tuckman
o NPD
o erisis Management Center
o Dispatch Center
3:15 Adjourn
Enclosure 2
ATTENDEES
NAME ORGANIZATION
L. Wiens NRC/NRR/PDII-3 T. Cooper NRC/RI/McGuire W. Orders NRC/SRI/Catawba D. Hood NRC/NRR/PDI1-3 D. Matthews NRC/NRR J. Frye Duke/QA/Audit L. Davison Duke/QA/General Office B. Dolin Duke/Design Eng./Catawba D. Murdock Duke/DE/McGuire R. Wilkinson Duke/NPD/Planning & Consulting D. Franks Duke/QA/McGuire G. Grier Duke/QA/G.O. J. Peele Duke/Design Eng./Oconee B. Futrell Duke/NPD/Nuc Safety Assurance B. Gill Duke/NPD/Regulatory Compliance R. Morgan Duke/NPU/Regulatory Compliance S. Ninh NRC/RI/McGuire F. Rinaldi NRC/NRR/PD1l-3 O K. Jabbour NRC/NRR P. Skinner NRC/SRI/Oconee M. Tuckman Duke/NPD/Nuclear Support B. Miller NRC/RII/Project Engineer H. Tucker Duke/NPD/G.O. P. Nardoci Duke/NPD/Regulatory Compliance P. Guill Duke/NPD/NSA W. Scott NRC/NRR/Performance
Evaluation Branch J. Ashe Duke/Trans/EM&C L. Tatum Duke/Trans/EM&C R. Holmes Duke/Trans/EM&C J. Hicks Duke/Trans/VP E. LeGette Duke/Oconee/Compliance W. Troskoski NRC/Office of Enforcement
AGENDA
Opening ReMarks
- Jim Hicks, Uice President Transmission
Transmission Department Organization
- Roy Holmes, Manager Transmission EMC
Training, Procedures, & Work Control Systems
- Jeff Ashe, Manager Plant Support
Closing ReMarks
- Jim Hicks, Uice President Transmission
Open The Floor For Questions
Why Is There A Transmission Organization
How Is Transmission Organized
What Transmission Does In Nuclear Plants
Plans To Strengthen Transmission Service
To Nuclear Plants
Transmission Department
U P Trasmission
Transmission mmmm Department Review Committee
Employee Relations Administration Line & Safety & Services Maintenance &
Construction
.o Electrical
Operations Maintenance & Engineer Construction
Transmission Department
EMC Division
Manager
EMC Division
District Manager District Manager District Manager Manager Manager EMC EMC EMC EMC EMC
Charlotte Greenville Greensboro Electrical Supt. Plant Maint.
Manager Plant Support
Transmission Department
EMC Division
Charlotte District
Greensboro District
Greenville District
District Manager
EMC
Supervisor
Planning
District District EngieerEngne. Superintendent Superintendent Superintendent
Relaying Nhr Meter Test Steel Breakers Batteries Controls Meter & Instr. Foundation Cable Transformers
Computer Control House Aux. Systems Capacitors Maintenance
Doble Testing Switchgear
Paint
Transmission Department
EMC Division
Plant Maintenance Section
Manager
EMC
Plant Maintenance
Engineer
Superintendent Superintendent Manager
Plant Support
Generator Motor Nuclear Station Generator Testing Bus Support Engineers
Excitation Systems
Maintenance Services For Nuclear Plants
- Breakers - 600 volt to 500,000 volt
a Motors - 4160 and 6900 volt
* Protective Relaying - 600 to 500,000 volt Systems
* Transformers - 600 volt to 500,000 volt
Power Transformers
* Metering and Instrumentation - Electrical Systems
1OCFR Duke Drawings FSAR PIR / LERs SER Valve / Equipment Lists Standard Review Plan I & C List Branch Technical Positions System Descriptions Tech. Specs. Current NSM Packages Duke Nuclear Guides Fire Protection Safe Shutdown Licensing Correspondence Review Manual ANS Standards Fire Protection Review Manual ANSI Standards Response to TMI Concerns t E Standards Response to NUREG-0588 IEE Standards Plant Environmental Parameters SITA Audit Findings Manual INPO SOERs EQRI Manual NSSS Correspondence Testing Correspondence Files - Station Task Force(testing) Specifications - IWP/IWV Code (ASME Section XI) Calculations - IWP/IWV Manual Manufacturer Drawings and - NPD Directives on Retest
Manuals - Station Procedures and Retest List
- Design Studies on Testing
DESIGN BASES HIERARCHY
PLANT DB
SYSTEM DB
SYSTEM DC
EQUIPMENT DC
DB = DESIGN BASES
DC = DESIGN CRITERIA
Page 4
SECTION 10.0 INTRODUCTION *Boundary and Scope
*System Purpose
*Format and Use
SECTION 20.0 DESIGN BASES AND CRITERIA
*ONLY safety-related and regulatory required system and equipment design bases.
PIP PROCESS INVOKED IF VIOLATED
SECTION 30.0 SYSTEM/STRUCTURE DESCRIPTIONS
*Description of safety and nonsafety functions
*Nonsafety-related and nonregulatory required design bases
FIGURE 1. OUTLINE OF SPECIFICATION SECTIONS
corm 45O69 (R 10-98)
System Design Bases/Objectives
Design Basis: The VG system shall supply control air at sufficient pressure to keep the emergency diesel generator running (Reference section 20.1.2 of specification no. MCS-1609.VG-00-0001).
Objective: Verify that a control air pressure of no less than 90 psig and no greater than 135 psig is maintained, after the diesel starts, while the emergency diesel generator is running for 24 hours (Tech. Spec. 4.8.1.1.2e(8)). The starting air compressors shall be available to start during this test.
Test Frequency: The control air test shall be performed with the same frequency as the emergency diesel start test.
Operability: If a diesel fails this test, then it shall be declared inoperable.
Test Acceptance Criteria
Test/Measurement Reference Document Acceptable Value Including Tolerance
ontrol air pressure TT/OB/9100/300 90 < P < 135 psig
Tech. Spec. 4.8.1.1.2e (8)
2/15/89 letter from JR Hilley to F Schubert
DUKE POWER COMPANY QA COND 1
McGuire Nuclear Station, Units 1 & 2 Design Basis/Test Acceptance Criteria Emergency Diesel Generator Control Air
OSN/DTE &AdL - INS/TE._.A C /f __________ ------ CHK/DTEt~ i;I-qN/T4D~d-.C
CUK/DTE____ __ - 4,. INS/DTE s
C :I REVISIONS DSN R DE CD
NO - REVISIONS DSN CHKIAPR OTE C/E ELE M/N DWG NO MCDB-1609-VG.S002-O1 TREV 0
WEja(m tcs!W .VG-0l
F33/35 -- R 21/23
P~ LINE PURIFIER l/BATMOSPHERE
61/65 115/117 7Yn1 AIR [NLET HIR RN FILTER AS/BI
STARTING AIR DRYER Al81 AFTERCOOLER AIR 62/66 TANK Al/ RlI/Bl COMPRESSOR Al/BI
83/84 VOLUME TANK A/B
DIESEL VI BLACKOUT CONTROL AIR ENGINE HEAD3ER HEADER
A/B 939 91034NOTE Z CONTROL AIR FILTER A/B 79/80
77/78 90/92 n18/20
34/36 "41 RN
63/67 ZZ/Z4
-- vATMOSPHERE 64/68 LINE 116/118 1I1
PUIIRA2/82 AIR INLET PURIFAIER AZ/BZ IR RN FILTER AZ/BZ STARTING AIR DRYER R2/82 AFTERCOOLER AIR
TANK A2/B2 R2/B2 COMPRESSOR AZ/BZ
NOTES u
1. EACH UNIT HAS TWO DIESEL ENGINES (A AND B). EACH ENGINE HAS TWO STARTING AIR SUBSYSTEMS (AS SHOWN ABOVE). BOTH R AND B SUBSYSTEMS EQUIPMENT TAG NUMBERS ARE DISPLAYED.
Z. SOLENOID VALVES VGSVSI6/5170.5161/5171.5162/5172 AND 5163/5173 ARE LOCATED ON THE CONTROL AIR HEADER. SEE IC DETAILS MC-1499-VG3 AND MC-2499-VG3. TYPICAL FOR UNITS I AND 2
LE= ooty 1o1 Colme IS AI 911 FLOW ODViKA. DUK -ME - -- -- -_
Ll lEVI 0puLe L t So-w .P_ _CGUIRE PDSaAR STATION
- I-- -- --- SUM"FIRT
VALt -E I -wo -e DIESEL GENERATOR ENGINE mJK IUOIE -9200"M HC-1609-4.0 VG SYSTEM CUNIT I)O
(IHC-69-4.0 VG SYSTEM UNIT 21SRN R SYSTE ve)
RELIEF VALVE assIRE(661 v19 ETWE i s _e_____ SFLOV DIC ORMNOL
DsignDesign Design Design Design Input Process Output
Documents
Discrepancy FIGURE 2. Design Basis Discrepancy
Safety N Resolution Process Concern?
Operability Y Reportability Evaluation Evaluation
Oper. N N Rep. Issue? Issue?
Y Y
Take Tech Spec Complete Report NRC or other action DB3 Activity to NRC Enforcement
Policy
Final Evaluation
Closeout
KEY POLICY PROPOSALS
OPERABILITY * Evaluate at deliberate pace * Presumption of operability
REPORTABILITY * Presumption of conformity * Combine related items in single LER
ENFORCEMENT * No violations
USE OF SOURCE TERM IN REGULATION CURRENT SITING REQUIREMENTS
SITING REGULATION IS 10 CFR 100.
PART 100 REQUIRES THAT EVERY REACTOR SITE DEFINE:
1) AN EXCLUSION AREA - NO RESIDENTS, CONTROLLED BY APPLICANT
2) LOW POPULATION ZONE (LPZ) - "LOW" DENSITY OF RESIDENTS PERMITTED - NEAREST DENSELY POPULATED CENTER
AT LEAST 1 1/3 TIMES LPZ OUTER RADIUS.
PART 100 ASSUMES EXISTENCE OF LOW-LEAKAGE CONTAINMENT.
CALCULATED DOSES AT EAB AND LPZ MUST MEET PART 100 GUIDELINES (25 REM WHOLE BODY AND 300 REM THYROID) FOR 2 HOUR AND 30 DAY PERIODS, RESPECTIVELY.
1
USE OF SOURCE TERM IN REGULATION CURRENT SITING PRACTICE
* FISSION PRODUCT RELEASE IS DERIVED FROM TID-14844 (1962), AND PRESENTLY GIVEN IN REG. GUIDES 1.3 AND 1.4
- 100 PERCENT OF NOBLE GASES - 50 PERCENT OF IODINE (HALF OF THIS IS THEN
ASSUMED TO PLATE OUT IN CONTAINMENT) - INSTANTANEOUS APPEARANCE - IODINE CHEMISTRY GIVEN (LARGELY 12)
* CONTAINMENT IS ASSUMED TO LEAK AT MAXIMUM LEAK RATE ALLOWED IN TECH. SPECS.
* FISSION PRODUCT CLEANUP SYSTEMS (SPRAYS, FILTERS) EVALUATED CONSERVATIVELY.
* DOSES CALCULATED USING CONSERVATIVE SITE METEOROLOGY.
2
WHAT CAN WE DO WITH WHAT WE HAVE LEARNED AND WHY?
CURRENT SET OF REGULATIONS AND GUIDANCE HAS SERVED WELL TO SET CERTAIN PLANT DESIGN AND SITE PARAMETERS.
TID-14844 DID NOT ORIGINALLY CONTEMPLATE CREDIT FOR THE USE OF FISSION PRODUCT CLEANUP SYSTEMS.
AS THE SIZE OF PLANTS INCREASED, HOWEVER, FISSION PRODUCT CLEANUP SYSTEMS BECAME NECESSARY TO KEEP EXCLUSION AREAS FROM BECOMING VERY LARGE AND RELIANCE ON SUCH SYSTEMS INCREASED.
AS CURRENTLY APPLIED, PART 100 AND ASSOCIATED REGULATORY GUIDES PRIMARILY INFLUENCE PLANT DESIGN AND INFLUENCE SITING TO A MUCH LESS EXTENT (SITING GOVERNED BY REG. GUIDE 4.7).
FURTHER, PART 100 DOES NOT ADDRESS THE ISSUE OF CONTAINMENT FAILURE WHICH IS THE PRIMARY CONTRIBUTOR TO RISK.
3
WHAT CAN WE DO WITH WHAT WE HAVE LEARNED AND WHY?
(CONTINUED)
* HOWEVER, CURRENT PRACTICE DOESN'T INCLUDE UPDATED UNDERSTANDING OF SOURCE TERM FORM, CONTENT, AND BEHAVIOR AND RESULTS IN DESIGNERS INCLUDING DESIGN FEATURES THAT MAY NOT BE IN THE DIRECTION OF ENHANCED SAFETY.
* NEW DESIGNS UNDER REVIEW.
* THEREFORE, THE STAFF IS CONSIDERING CHANGES TO CURRENT PRACTICE FOR FUTURE LWRs THAT WOULD:
- GIVE DESIGNERS MORE FLEXIBILITY TO DEVELOP DESIGNS WITH SAFETY FEATURES THAT ENHANCE SAFETY BY UTILIZING REALISTIC SOURCE TERM ASSUMPTIONS, AND
- MORE DIRECTLY ADDRESS ACCEPTABLE SITE PARAMETERS.
4
OPTIONS FOR IMPROVEMENT TO CURRENT PRACTICE
* CONTINUE CASE-BY-CASE REVIEW (E.G., PER SECY-90-16 FOR ABWR):
- DESIGN CERTIFICATION PROCESS.
* TECHNICAL UPDATE:
- UPDATE TID, R.G.s, SRP TO REFLECT LATEST UNDERSTANDING OF SOURCE TERM AND ASSOCIATED METHODOLOGY, BUT NO RULE CHANGE.
* DECOUPLING:
- UPDATE REGULATIONS AND GUIDANCE TO STATE SEVERE ACCIDENT DESIGN CONSIDERATIONS AND SITE PARAMETERS.
UPDATE TID, REG. GUIDES 1.3 AND 1.4 AND CORRESPONDING SRP SECTIONS TO RECOGNIZE CURRENT UNDERSTANDING OF SOURCE TERM:
- TIMING OF RELEASE - FORM AND CONTENT OF FPs.
RETAIN 10 CFR 100 DOSE GUIDELINES AND SITING GUIDANCE CONTAINED IN REG. GUIDE 4.7.
RETAIN CURRENT CONTAINMENT DESIGN BASIS (LOCA) AND ASSUMPTIONS, BUT EVALUATE CONTAINMENT PERFORMANCE UNDER LIKELY SEVERE ACCIDENT CONDITIONS.
CHANGES WOULD BE MADE TO SUPPORT EVOLUTIONARY LWR REVIEW.
APPLICATION OF THESE CHANGES TO EXISTING PLANTS NEEDS TO BE CONSIDERED.
6
PRELIMINARY RECOMMENDATIONS - STEP 2 DECOUPLING
EVALUATE FURTHER THE BENEFITS, DISADVANTAGES, AND SCOPE OF DECOUPLING PLANT DESIGN AND SITING FOR FUTURE LWRs. SPECIFICALLY LOOK AT:
- MODIFYING 10 CFR 100 TO SPECIFY ACCEPTABLE SITE PARAMETERS AND TO REMOVE REQUIREMENT FOR CALCULATION OF DOSE, AND
- MODIFYING 10 CFR 50 TO SPECIFY ACCEPTABLE PLANT DESIGN PERFORMANCE AND FEATURES (SUCH AS CONTAINMENT LEAK RATE AND FISSION PRODUCT CLEANUP SYSTEMS) CONSIDERING SEVERE ACCIDENTS.
